The “Paid Sick Days Act” (the “Act”), which was passed by the Pittsburgh City Council on August 3, 2015, is set to take effect on January 11, 2016. We previously issued an alert detailing many of the Act’s provisions. At that time, it was still not clear when the Act would be effective. However, the City of Pittsburgh Office of the Controller recently announced the January 11, 2016 effective date. Accordingly, barring a successful challenge to the Act, as of January 11, 2016, covered employers must comply with the Act and eligible employees will begin accruing sick time under it.

The Paid Sick Days Act: An Update

The Act provides the Office of the Controller with the authority to promulgate guidelines and regulations to implement and enforce its provisions. To date, neither guidelines nor regulations have been issued as they continue to be developed during the time leading up to the Act’s effective date. However, the website of the Office of the Controller does provide additional information regarding requirements for employers, as well as a list of frequently asked questions. Additionally, employers can access notices that they will be required to post, beginning January 11, 2016.

The Act has been challenged by certain local employers, which argue that its passage by the Pittsburgh City Council constitutes “an illegal exercise of municipal authority” and seek a declaration that the ordinance is “null and void.”

While there is uncertainty as to whether the Act will survive these legal challenges, with just over two months until the effective date, employers should continue to review existing policies to determine if they meet the requirements of the Act, or draft new policies to comply.

Leech Tishman will provide updates on the Paid Sick Days Act, including the issuance of regulations and the outcome of litigation. Leech Tishman is available to assist your organization with any questions regarding the Paid Sick Days Act, and can also provide guidance with respect to implementing and enforcing appropriate policies and procedures, and providing notice.